OMB to agencies: Ask users if your forms make sense

By Charles S. Clark

August 10, 2012

The White House is asking designers of federal information-gathering forms to pretest them for maximum simplicity.

In an Aug. 9 memo to department heads, including chiefs of regulatory agencies, Cass Sunstein, the outgoing administrator of the Office of Information and Regulatory Affairs, wrote that while government communicators have made progress toward simplifying federal forms, “it is a continuing challenge for agencies to minimize complexity and confusion.”

Forms and their accompanying instructions imposed on citizens for paying taxes, obtaining licenses or applying for grants, if poorly designed or unduly complex, “can prove difficult and confusing, especially for individuals and small businesses,” Sunstein wrote. “Unnecessarily burdensome paperwork requirements can undermine economic and other goals.”

The sorts of advance testing the Office of Management and Budget recommends include “focus groups, in-person observations of users' perceptions of the forms and questions (cognitive testing), Web-based experiments, and randomized controlled experiments,” Sunstein wrote.

An example he gave in an accompanying blog post involved labels explaining improved fuel economy in motor vehicles introduced in 2011 by the Environmental Protection Agency and the Transportation Department. “The new labels promote informed choices by telling consumers, clearly and simply, about annual fuel costs and about the likely five-year savings or costs of particular cars (compared to the average vehicle),” he wrote. “The new labels followed an extensive process of testing, to see what really would be most useful for consumers.”

Sean Moulton, director of federal information policy at the nonprofit OMB Watch, told Government Executive that while he supports the “whole idea of simplifying forms, regulations and legislation to make them more understandable and accessible, the risk is we can go too far. Nothing in the memo itself indicates any kind of limit, so it will be up to the agencies.”

He recalls an effort by the Environmental Protection Agency during the George W. Bush administration to ease the reporting burden on industry in the area of toxic release inventory. As part of simplification, the agency proposed switching from requiring forms annually to requiring them every other year. The effort was abandoned after “so much pushback,” Moulton said.

“Simplification can be a big boon, especially for small business, and hopefully technology” will allow people to avoid having to re-enter the same information repeatedly, he added. “But we have to make sure forms still serve their purpose in collecting the information needed and identifying people sufficiently.”